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RRT VI Structure

RRT VI Structure. Standing RRT Standing Committees Preparedness Response S & T Committee Industry Incident Specific RRT. 13 RRTs comprised of 15 Federal agencies plus State representatives Co-chaired by EPA and USCG Engage in planning and training activities year-round

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RRT VI Structure

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  1. RRT VI Structure • Standing RRT • Standing Committees • Preparedness • Response • S & T Committee • Industry • Incident Specific RRT

  2. 13 RRTs comprised of 15 Federal agencies plus State representatives Co-chaired by EPA and USCG Engage in planning and training activities year-round Coordinate decision making process for alternative cleanup operations I X II VIII V III VII IX IV VI Alaska Regional Response Teams(RRTs) Oceania Caribbean • Provide technical expertise • and resources to the OSC • during a response

  3. RRT STANDING AGENCY BODY

  4. Alternate Response TechnologiesEvaluated at RRT Level • Dispersants • In Situ Burns • Surface Washing Agents • Bioremediation Agents • Bioremediation Agents • Natural Sorbents • Solidifiers

  5. ESA, EFH Consultations

  6. Structure of Section 106 Response Approved 6/24/2010 Historic Properties Specialist (Reports Directly to FOSC at UAC) Tribal Consultation Coordinator Federal or Federal Contracted (20) Responsible Party Contracted (78) ICP ICP Houma Mobile ICP Miami Historic Properties Specialist’s Rep. Historic Properties Specialist’s Rep. Historic Properties Specialist’ Rep. SHPO Liaison (2) SHPO Liaison (2) SHPO Liaison (2) Tribal Liaison Tribal Liaison Tribal Liaison GIS Data Tech GIS Data Tech GIS Data Tech Traditional Cultural Properties Ethnographer Traditional Cultural Properties Ethnographer Traditional Cultural Properties Ethnographer Archeology Crew Chief (3) Archeology Crew Chief (5) Archeology Crew Chief (4) Archeology Crew Members (15) Archeology Crew Members (23) Archeology Crew Members (18) Administrative Support (1) Administrative Support (2) Administrative Support (1) Historic Architect Historic Architect Historic Architect Architectural Conservator Architectural Conservator Architectural Conservator

  7. Incident: Deepwater Horizon Accepted Structure of Section 106 Response Cultural Resource Management Structure for Each ICP Historic Properties Specialist Archeology Crew Chief 1 per 5 Crew Members SHPO Liaison SHPO Liaison Archeology Crew Members Tribal Liaison GIS Data Tech Historic Architect Admin. Asst. Architectural Conservator TCP Ethnographer Administrative Support Federal or Federal Contracted Responsible Party Contracted

  8. Louisiana SOSC Authority for Oil Related Coastal Spill Response Issues

  9. Louisiana SOSC Authority

  10. Louisiana NRDA Trustees Office of Coastal Protection And Restoration Louisiana Oil Spill Coordinators Office Department of Natural Resources Department of Environmental Quality Department of Wildlife and Fisheries

  11. 40 CFR 300.180 - State and local participation in response. • (a) Each state governor is requested to designate one state office/representative to represent the state on the appropriate RRT. The state's office/representative may participate fully in all activities of the appropriate RRT. Each state governor is also requested to designate a lead state agency that will direct state-lead response operations. • This agency is responsible for designating the lead state response official for federal and/or state-lead response actions, and coordinating/communicating with any other state agencies, as appropriate...

  12. Inter-Regional RRT Coordination of Alternate Response Technologies

  13. Jurisdictional Boundaries- Region VI EPA MSU MORGAN CITY SECTOR HOUS-GALV SECTOR HOUSTON-GALV SECTOR CORPUS CHRISTI MSU PORT ARTHUR SECTOR NEW ORLEANS

  14. Jurisdictional Boundaries - Region IV EPA SECTOR JACKSONVILLE SECTOR NEW ORLEANS SECTOR MOBILE SECTOR ST. PETE SECTOR MIAMI

  15. Cross –Regional Coordination

  16. RP Responsible Party FOSC ACTIVATE GST & SMART PROTOCOL Dispersant Asset on STBY

  17. Original Dispersant Pre-Auth Consults

  18. Request Advance Deployment NMT 48 Hours in advance Targets proposed STOP Weather Skimmer availability ISB not practical NO Targets Justified? Re-Justify? YES NO STOP YES Monitoring Justification Location Trajectory ICC develops briefing package for FOSC NLT: 1800 CDT ICC/Houma FOSC EPA-6/RA Justification NO YES

  19. Morning of Deployment AM Targeting Flight 06:00-07:00 Who gets the intel? Changes Can be justified Significant Changes 08:00 NO YES STOP NO FOSC EPA/Robert NOAA 08:30 STOP NO YES YES DEPLOY

  20. 40 CFR 300.915 (d) The OSC may authorize the use of any dispersant, surface washing agent, surface collecting agent, other chemical agent, burning agent, or miscellaneous oil spill control agent, including products not listed on the NCP Product Schedule, WITHOUT obtaining the concurrence of the EPA representative to the RRT and, as appropriate, the RRT representatives from the states with jurisdiction over the navigable waters threatened by the release or discharge when, in the judgment of the OSC, the use of the product is necessaryto prevent or substantially reduce a hazard to human life.

  21. Surface Dispersant for Health and Safety FOSC Issues Approval for Surface Dispersant Yes Vessels Follow Existing H&S Plans for Dispersant Use Does the Revisited H&S Plan Involve the Use of Dispersants Nightly Report Correlating VOCs and Dispersant Applications No Yes Does the Data Justify the use of Dispersants If 2 consecutive Days, Re-Evaluate the use of Dispersants for Health and Safety No STOP USE OF SURFACE DISPERSANTS FOR HEALTH AND SAFETY

  22. Cross –Regional Coordination

  23. NRT Authorized In-Situ Burns via R6 Pre-Auth

  24. Cross –Regional Coordination

  25. RRT IV Incident Specific Approval of SWA off MS, AL, & FL

  26. Cross –Regional Coordination

  27. Note that the listing of “XXXX” on the NCP Product Schedule does not constitute approval, certification, authorization, licensing or promotion of the product; nor does it imply compliance with any criteria or minimum standards for such agents. Failure to comply with these restrictions or the making of any improper reference to EPA in an attempt to demonstrate approval or acceptance of the product will constitute grounds for removal of the product from the schedule.

  28. What is the Product Schedule? • Required by Section 311(d)(2)(G) of the CWA • Compiles chemicals and other agents that may be used to carry out the NCP, waters they may be used in, and quantities that may be used. • Listing in the schedule gives: • The RRT the power to pre-approve usage under certain conditions and in specific locations with “preauthorization plans” – 300.910(a) • The OSC the power, with concurrence/consultation of select RRT members, to approve the use “on the fly”. – 300.910(b) • EPA co-chair and State reps of States with jurisdiction over the effected or threatened waters: concurrence • US DOI and US DOC trustees: consultation • Not listed on the schedule? No approval can be granted… • Except by an OSC to prevent or “remove a hazard to human life.” • 300.910(d) – the only place the NCP states “human life”

  29. Subpart J applies only to water, right? • No – 300.900(b) • “…adjoining shorelines…activities that may effect natural resources belonging to, appertaining to, or under exclusive management of the United States…”

  30. What are defined “natural resources”?? • Natural resources – 300.5 • Land, fish, wildlife, biota, water, groundwater drinking water supplies, and other such resources belonging to, managed by, held in trust by, appertaining to, or otherwise controlled by the United States…any state or local government, any Indian Tribe, or if such resources are subject to a trust restriction on alienation, any member of an Indian Tribe.

  31. Use in Headwaters vs Main Streams • NCP and CWA 311 do not distinguish between them. • RRT’s responsibility to approve, or not, per 40 CFR 300.910

  32. 40 CFR § 300.910 Authorization of use. •  (b) For spill situations that are not addressed by the preauthorization plans developed pursuant to paragraph (a) of this section, the OSC, with the concurrence of the EPA representative to the RRT and, as appropriate, the concurrence of the RRT representatives from the states with jurisdiction over the navigable waters threatened by the release or discharge, and in consultation with the DOC and DOI natural resource trustees, when practicable, may authorize the use of dispersants, surface washing agents, surface collecting agents, bioremediation agents, or miscellaneous oil spill control agents on the oil discharge, provided that the products are listed on the NCP Product Schedule.

  33. Senate Hearings and Congressional Inquiries: Example of Political Pressure being exercised by vendors whose products were not being purchased for the spill response

  34. Cross –Regional Coordination

  35. Request to the FOSC for alternative spill product use DWH Process for Alternative Spill Product Use Flowchart Awaits operational need from FOSC/R Houma EU provides strategies list to FOSC /R & Ops sections for potential use Source of request is of a political nature? Source of request is of a political nature? Request the sender provide idea to DWH IATAP website no Houma EU & RDC develop strategies for potential use Yes UAC EU Replies to sender that request has been forwarded to EPA RDC notifies BP of successful test Product on NCP product schedule? Forward request to EPA Reg & Policy Division no RDC notifies Requestor of unsuccessful test yes Yes Is the request for pre –operational test? Test sucessful? Request /assist the originator in completing RRT 6 Small-Scale Alternative Shoreline Testing Checklist UAC EU forwards to CG RDC ARTES - Houma for testing RDC ARTES prioritizes request & conducts test yes no no no Is the request for operational use? Was the product tested using RRT6 small scale checklist? Go to next page yes yes

  36. FOSC/R determined operational need? Notify requestor a product awaits operational need from FOSC/R no Yes Request /assist the originator in completing operational plan for the product within RRT Guidelines Is plan consistent with RRT 6/4 guidelines? Is the product RRT pre-authorized for use? yes yes FOSC/R executes plan & provides report as required no no Approval granted? FOSC/R executes plan & provides report as required Requestor ensures plan meets RRT guidelines RRT or FOSC provides explanation of denial FOSC/R requests RRT approval yes RRT provides explanation of denial no

  37. LT 400 Acres of LA Marsh Impacted

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